TAX CONTROVERSY & PLANNING — WASHINGTON, DC
Audits, liens, levies, and letters that ruin breakfast — resolved by attorneys who've spent 20 years on both sides of the examination table. Attorney-client privilege included; your CPA can't offer that.
SCHEDULE A — SERVICES
Controversy work when the government comes calling; planning work so it doesn't call again.
Field, office, and correspondence audits managed end to end — you never sit alone with an examiner.
DEFENDED IRC 7122Settling tax debt for what the law actually allows — computed correctly, documented bulletproof.
SETTLED IRC 6320/30Collection due process appeals and emergency releases when the IRS reaches for accounts or wages.
RELEASED T.C. Rule 20When Appeals won't move, we petition. Admitted to the U.S. Tax Court with a trial record the IRS counsel's office knows.
LITIGATED FBAR/8938Streamlined filings and voluntary disclosures that fix the past without inviting worse.
DISCLOSED Subchap. S/KEntity structuring, exec comp, and transaction planning — the cheapest tax fight is the one structured away.
PLANNEDTHE RECONCILIATION
Recent matters, entered the way we think about them: what the government claimed, and what our clients actually paid.
Illustrative matters. Tax outcomes depend on individual facts, filings, and law; no result is guaranteed.
PROCEDURE
Every engagement starts with the transcript — what the IRS's own records say — before anyone pays anything.
We obtain your full IRS account transcripts and decode what's actually assessed, accruing, and expiring — often different from the letters.
A written memo: worst case, likely case, and our recommended posture, with statute-of-limitations dates calendared.
Appeals conferences, settlement officers, or Tax Court — chosen by leverage, not habit.
Resolution plus the planning to keep you out of the next audit cycle. One clean ledger, going forward.
COUNSEL
LL.M.s in taxation, Tax Court admission, and government experience — the trifecta this work demands.
Managing Partner · Controversy
Eleven years as an IRS senior attorney before crossing the aisle. Miriam has negotiated with every flavor of revenue officer and knows precisely which arguments move Appeals — and which waste your money.
LL.M. Taxation, Georgetown · U.S. Tax Court · Former IRS Office of Chief Counsel
Partner · Planning
Structures businesses, exits, and estates so the controversy team stays bored. Peter's clients call him before term sheets, not after notices — the order matters.
LL.M. Taxation, NYU · CPA (inactive) · ABA Tax Section
Partner · Collections Defense
The emergency line. Levies released, garnishments stopped, and payroll saved — often within 72 hours. Dana treats collection deadlines like the emergencies they are.
J.D., GW Law · CDP appeals specialist · 900+ collection matters
"The IRS said $2.4 million. Miriam's team proved most of it was a payroll company's error and settled the rest. We kept the restaurants — all of them."
Restaurant group owner"A levy hit our operating account on a Wednesday. By Friday it was released and we made payroll. I don't know how to price that."
Construction company CFO"Fifteen years of offshore accounts I didn't know how to fix. The disclosure went through cleanly. I sleep now."
Retired physicianBEFORE THE DEADLINE
Most IRS letters carry 30- or 90-day response windows that determine your rights forever. A consultation now preserves every option.